1. Purpose
This policy sets out Murzo Group's approach to financial promotions, fundraising communications, investment materials, investor decks, property venture communications, asset-backed claims, returns statements, and other communications that may influence an investment, lending, funding, or financial decision.
The purpose is to prevent unlawful regulated activity, misleading financial promotions, unauthorised investment offers, exaggerated returns, unclear risk statements, and reputational harm.
2. Scope
This policy applies to websites, emails, social media, pitch decks, brochures, term sheets, calls, webinars, private messages, adverts, property materials, asset valuations, cultural object statements, high-value goods statements, lender materials, shareholder communications, and any document or communication that discusses investment, funding, returns, ownership, profit, lending, shares, bonds, cryptoassets, collective schemes, or financial products.
3. Policy Position
Murzo Group must not make a financial promotion or carry on regulated activity unless the communication and activity have been checked and approved by suitably authorised people.
Communications must be fair, clear, accurate, balanced, and not misleading. A statement that is technically true can still be misleading if it hides material risks, conditions, assumptions, conflicts, costs, or uncertainty.
4. Restricted Communications
- Offers or invitations to invest in Murzo Group or any project, property, asset, collection, venture, fund, product, or entity
- Statements about guaranteed, expected, projected, historic, or target returns
- References to shares, bonds, loans, notes, cryptoassets, pooled investments, investor rights, profit sharing, or capital growth
- Materials using phrases such as low risk, secure, asset-backed, guaranteed, fixed return, passive income, or protected capital
- Property, cultural object, high-value goods, or commodity materials that imply investment performance or resale profit
- Any communication aimed at retail investors, overseas investors, high-net-worth individuals, sophisticated investors, lenders, or public fundraising audiences
5. Approval Controls
Financial promotion and fundraising materials require approval before release. The approval level should reflect the audience, country, amount, product, channel, and whether regulated activity, securities law, consumer credit, cryptoasset, insurance, mortgage, collective investment, or crowdfunding rules may apply.
- Check whether FCA authorisation, approval by an authorised person, or a lawful exemption is needed
- Check whether overseas securities, promotion, crowdfunding, private placement, or investor rules apply
- Check that risk warnings, assumptions, eligibility restrictions, and conflicts are clear
- Check that valuations, forecasts, projections, and performance statements are supportable
- Check that the communication is consistent with Murzo Group's public communications and green claims controls
6. Prohibited Conduct
- Promising or implying guaranteed investment returns without a lawful and supportable basis
- Using pressure, scarcity, urgency, celebrity, media, or prestige references to push investment decisions
- Publishing investor materials before legal, regulatory, tax, and financial approval
- Describing a regulated financial product or activity as a simple commercial opportunity to avoid controls
- Targeting consumers in a country where Murzo Group has not checked promotion and securities rules
7. Media, Reputation and Third Parties
Press, influencer, broker, introducer, affiliate, agent, or partner communications must not make unapproved financial claims for Murzo Group.
No person may use names such as The Financial Times, Forbes, Sky News, Bloomberg, BBC News, FTSE 100, London Stock Exchange, Chinese Stock Exchange, Saudi Stock Exchange, or similar prestige references in a way that implies endorsement, listing, coverage, investment status, or authority where that is not true and approved.
8. Evidence and Withdrawal
Approval evidence and supporting material should be limited to what is needed to support the communication, respond to advisers, authorities, platforms, investors, or disputes, and manage withdrawal if the communication becomes inaccurate.
Murzo Group may remove, correct, suspend, or replace communications where the law, facts, audience, risk, or regulatory position changes.
9. Review
This policy will be reviewed before any fundraising campaign, investment communication, property venture promotion, asset-backed offer, cryptoasset-related communication, or public investor-facing material.
